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Alexander J. Cotoia currently serves as the Regulatory Compliance Manager at The Volkov Law Group, where he regularly advises the firm and its clients on the latest developments implicating trade compliance concerns. He may be reached at acotoia@volkvovlaw.com; As global political tensions continued to escalate on multiple fronts,
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A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you. I know I am scratching my head trying to make sense of the whole picture here. There are a number of significant indicators of a change in DOJ's tack, along with
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When it comes to FCPA enforcement and expectations, DOJ has moved the goalposts. Some would argue that DOJ has been consistent all along. The truth, like most issues, lies somewhere between the extremes. With lots of fanfare, DOJ implemented a new Corporate Enforcement Program to udnerscore its intent to examine
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Life is always filled with surprises. Just when we thought 2023 was a "slow" FCPA enforcement year, DOJ and SEC announced a large enforcement action against SAP for approximately $220 million for FCPA violations in South Africa, and Indonesia. The SEC's enforcement action for $98 million
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Perhaps it is fitting to end this unusual FCPA enforcement year with another in a series of compliance reminders -- the quickest way to experience a bribery scandal is to ignore third-party risks. This has been a continuing theme this year and Freepoint is yet another example of why managing
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The Justice Department's FCPA enforcement record for 2024 was slow. This trend was unexpected, contrary to my own predictions and of various other prognosticators. It is hard to explain why this slowdown occurred. DOJ's record is hard to square against DOJ official speeches, statements and policy
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While 2023 was a relatively slow year in FCPA enforcement, the DOJ and SEC settlements announced throughout the year set out a list of important ethics and compliance reminders. While these may seem obvious to everyone, I hope they stimulate further reflection and analysis to inform FCPA compliance practitioners as
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FCPA trends often are relatively easy to describe and often overblown as a marketing technique by the usual cast of paparazzi suspects. (Self-proclaimed prognosticators that often push incorrect themes to promote business, or those that restate profound grasps of the obvious). 2023 has been a strange year in a
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This article was jointly authored by Alexander J. Cotoia, Regulatory Compliance Manager at The Volkov Law Group, and Daniela Melendez, Associate at The Volkov Law Group. Alexander and Daniela may be reached at their respective email addresses of acotoia@volkovlaw.com and dmelendez@volkovlaw.com. On December 14, 2023, Congress
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Alexander J. Cotoia currently serves as the Regulatory Compliance Manager at The Volkov Law Group, where he regularly advises the firm and its clients on the latest developments implicating trade compliance concerns. He may be reached at acotoia@volkvovlaw.com. On December 22, 2023, President Joseph R. Biden, Jr. issued
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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has renewed its commitment to squeezing Russia’s oil proceeds, releasing updated guidance with enhanced attestation and record-keeping requirements for maritime shipping operators and other industries that participate in the transport of Russian oil. OFAC
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Join Diligent and The Volkov Law Group for a webinar on January 16, 2024 that explores the complexities of modern slavery and human rights compliance within the realm of third-party risk management. As organizations face heightened scrutiny and increasing expectations to uphold ethical standards, understanding and navigating the evolving